Demand - FERC its Own Worst Enemy?

DocUticker - The traditional approach to demand response of paying for a customer's electricity consumption reductions relative to an administratively set baseline is currently being advocated by the Federal Energy Regulatory Commission (FERC) as a way to foster the participation of final consumers in formal wholesale markets.
Any paradigm that sells "reductions" from an exogenous baseline will crowd-out the adoption of direct pricing options such as critical peak and real-time pricing. Thus, we fear that the adoption of this weak form of demand response will ultimately work against the adoption of a truly symmetric treatment of load and generation that is an essential component of an efficient wholesale electricity market. There is a significant risk of creating conditions that will crowd out true price response by focusing too much on DR programs with unverifiable baselines and reliability-based rather than price-based mechanisms for obtaining consumption reductions.
Full Paper linked here